[LETTERHEAD OF DSI PROPERTIES, INC.]
Via Edgar

August 22, 2008

Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington DC, 20549

ATTN: 	Kevin Woody, Branch Chief
        Howard Efron, Staff Accountant

Re: DSI Realty Income Fund XI
Form 10-KSB for Fiscal Year Ended December 31, 2007

File No. 0-18286

Gentlemen:

I am writing on behalf of DSI Realty Income Fund XI, a California Limited
Partnership, in response to a letter of comment from the staff of the
Securities and Exchange Commission (the "Staff")dated July 21, 2008
(the "Staff Letter").

In your letter you state: "we have reviewed your filing to determine if
you conducted the evaluation of your internal control over financial reporting,
as required by Exchange Act Rules 13a-15 and 15d-15,  and provided an
assessment and a conclusion as to the effectiveness of your internal control
over financial reporting, as required by Item 308T(a) of Regulation S-B."

Management had performed its assessment of our internal control over financial
reporting in 2007. It was management?s belief that the disclosure, under Item
8A, contained in our filing adequately reflected the fact that we did perform
an evaluation of our internal control over financial reporting during the
reporting period and that there were no material changes to report regarding
these controls. Per the Staff's recommendations we have revised our "Controls
and Procedures" disclosure to include clarification of our separate assessment
of internal controls over financial reporting into our current 10-Q for the
period ended June 30, 2008. We will incorporate these changes into all future
filings.

Per the Staff's recommendations we have revised our certifications to include
the introductory language of paragraph 4 and 4(b) of Item 601(b)(31) of
Regulation S-B into our current 10-Q for period ended June 30, 2008. We will
incorporate these changes into all future filings.

DSI Realty Income Fund XI acknowledges that:

* DSI Realty Income Fund XI is responsible for the adequacy and accuracy of
the disclosure in the filing;

* Staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings;
and

* DSI Realty Income Fund XI may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please direct comments and/or any questions you may have to me or
Richard P. Conway, SVP at (562) 493-3022.

Sincerely,

/s/ ROBERT J. CONWAY
__________________________________
Robert J. Conway
Chief Executive Officer
August 22, 2008